Nursing Homes not Adequately Prepared for Emergencies says OIG

Many Medicare and Medicaid certified nursing homes lack crucial provisions in their emergency preparedness plans. During 2009 – 2010 92 percent of nursing homes met Federal regulations for emergency plans and 72 percent for emergency training. After reviewing the emergency preparedness plans of select nursing homes, HHS’ Office of Inspector General (OIG) identified six areas of concern with the plans nursing homes had in place. Those six areas of concern were: staffing; resident care; resident identification, information, and tracking; sheltering in place; evacuation; and communication and collaboration. These areas represent tasks that nursing home often did not include in their plan and could affect residents during disasters. CMS has agreed to amend their regulations to include specific requirements for emergency plans and training.

Staffing. Ten of the twenty-four selected nursing homes’ plans did not include any recommended tasks for ensuring sufficient staffing levels to provide continuous care for residents during disasters, potentially leading to delays in meeting medical and other physical needs. Additionally 22 of the 24 plans did not include backup plans for staff unable to report to work during the disaster, and 19 of 24 plans lacked information regarding staffing requirements.

Resident care tasks. Eleven of the twenty-four selected nursing homes’ plans did not include any recommended resident-care tasks. For example, 23 of 24 plans did not describe how to handle resident illness or death during an evacuation or how to provide disaster counseling to residents. As another example, 15 of 24 plans did not contain information regarding specific characteristics and needs of residents.

The lack of detailed information about resident-specific needs (e.g. nasogastric or enteral feeding tubes, ventilator, and oxygen) and characteristics (e.g Alzheimer’s and dementia) could pose a threat to the well-being of residents by failing to signal the need for special transportation and necessary medical care and equipment.

Resident identification, information, and tracking tasks. Five of the twenty-four selected nursing homes’ plans did not include tasks related to identifying residents, transferring their information, or tracking the residents. For example, 7 of the 24 plans did not specify any methods of identifying residents (e.g. wirstband or nametag), and 11 plans did not specify what personal information must accompany residents during an evacuation.

Sheltering in place. Twelve of the twenty-four selected nursing homes’ plans did not include any of the recommend task for sheltering in place. For example, none of the 24 plans specified the amount of water needed to ensure sufficient supply for a minimum of 7 days.

Evacuation tasks. Eleven of the twenty-four selected nursing homes’ plans did not include any recommended tasks regarding evacuation procedures. For example 22 of the 24 plans did not describe how the nursing home would transport and protect medical records and medications during an evacuation.

Communication and collaboration tasks. Twenty-two of the twenty-four selected nursing homes’ plans lacked tasks for communicating with local long-term care ombudsmen, residents, and proper authorities during and after a disaster.

Recommendations. OIG made three recommendations to CMS and one recommendation to the Administration on Aging (AoA). CMS agree with the recommendation to revise Federal regulations to include specific requirements for emergency plans and training. CMS also agreed to update the State Operations Manual to provide detailed guidance for survey agencies on nursing home compliance with emergency plans and training, and to promote the use of checklists. AoA agreed with the recommendation to develop model policies and procedures for long-term care ombudsmen to protect residents during and after a disaster. Finally in a memorandum report, OIG outlined guidance that CMS can consider when revising the checklist for health care facilities.

Disaster frequency. More than most people would expect, disasters impact nursing homes. From 2007 to 2010 several disasters substantially affected at least 210 nursing homes in 7 states, forcing residents to evacuate or shelter in place in response to floods, hurricanes, and wildfires.

In March 2009 flooding of the Red River forced the evacuation of six nursing home in North Dakota. Across the river in Minnesota, one nursing home was evacuated and the residents of another sheltered in place. In May 2010, widespread flooding along the Mississippi and Cumberland Rivers in Tennessee forced the evacuation of at least two nursing homes. Another nursing home evacuated some of its residents, and the residents of four other nursing homes sheltered in place.

Within a span of 12 days in September 2008, Category 2 hurricanes Gustav and Ike made landfall in Louisiana and Galveston Texas. Hurricane Gustav forced the evacuation fo 92 nursing homes in the coastal parishes of Louisiana. Hurricane Ike, the third costliest hurricane ever to hit the United States, devastated Galveston Island and lead to a mass evacuation of the Texas gulf coast, including 84 nursing homes. In September 2010, Category 2 Hurricane Earl threatened the Outer Banks of North Carolina, forcing the evacuation of three nursing homes while the residents of three other nursing homes sheltered in place.

Wildfires threatened heavily populated areas near San Diego, California, during the fall of 2007 forcing the evacuation of five nursing homes while the residents of three others sheltered in place. In May 2009, wildfires near Santa Barbara, California, forced the evacuation of one nursing home while four other sheltered in place.